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This Code of Ethics (hereinafter, the ‘Code’) outlines the set of ethical and moral principles that underpin the activities of Proramillenote SRL (hereinafter, the ‘Company’), as well as the behavioral guidelines adopted by the Company both internally (in relations between employees) and externally (in relations with institutions, suppliers, customers, business partners, political and trade union organizations, as well as the media—hereinafter, the ‘Stakeholders’).
Adherence to these principles is of fundamental importance for achieving the corporate mission of Proramillenote SRL and ensuring its reputation within the socio-economic context in which it operates.
At the outset, it should be noted that Proramillenote SRL firmly believes that every activity must be conducted ethically, in alignment with the principle enshrined in Article 41 of the Constitution, which states that private economic initiative ‘cannot be conducted in conflict with the public interest or in a way that harms safety, freedom, or human dignity.’
This Code is binding for the directors and employees of Proramillenote SRL, as well as for all those who work and collaborate, either permanently or temporarily, on behalf of the Company (hereinafter, the ‘Recipients’).
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The conduct of the Recipients, at all corporate levels, is based on the principles of legality, correctness, non-discrimination, confidentiality, diligence, and loyalty.
LegalityPersonnel Selection
The evaluation and selection of personnel are conducted with fairness and transparency, respecting equal opportunities to align the needs of Proramillenote SRL with the professional profiles, ambitions, and expectations of the candidates.
Proramillenote SRL commits to taking all necessary measures to avoid any form of favoritism in the personnel selection process by using objective and merit-based criteria, respecting the dignity of the candidates, and ensuring the company’s proper functioning.
The hired personnel, even through the implementation of this Code, receive clear and accurate information about roles, responsibilities, rights, and duties of the parties involved.
Personnel Management
Proramillenote SRL protects and values its human resources, striving to maintain the necessary conditions for professional growth, knowledge, and skills of each person, providing appropriate training for professional updates and any initiatives aimed at pursuing this objective.
Proramillenote SRL encourages employee participation in the company life, providing participatory tools to gather opinions and suggestions from workers, ensuring their fullest participation.
While maintaining the utmost availability towards the Company, no employee can be compelled to perform tasks, services, or favors not required by their employment contract and role within the company.
The Company is firmly committed to combating incidents of mobbing, stalking, psychological violence, and any discriminatory behavior or conduct that is harmful to personal dignity both inside and outside company premises.
Relationships among employees must be conducted with loyalty, fairness, and mutual respect, in adherence to the values of civil coexistence and personal freedom.
Communication
Proramillenote SRL provides Stakeholders with appropriate communication tools through which they can interact with the company to submit requests, seek clarifications, or file complaints.Proramillenote SRL promotes effective corporate communication connecting the company with civil society, aiming to understand the community’s needs and aspirations and to disseminate its values and mission. The information distributed to Stakeholders is complete and accurate to allow recipients to make informed and conscious decisions. Proramillenote SRL’s advertising respects ethical values, protecting minors and rejecting vulgar or offensive messages.
Relations with Authorities and Public Administrations
Relations with Authorities and Public Administrations must be characterized by the utmost clarity, transparency, and cooperation, fully respecting the law and adhering to the highest moral and professional standards. Recipients, unless expressly authorized, may not engage with Authorities and Public Administrations on behalf of Proramillenote SRL. In dealings with Public Officials, Public Service Appointees, and Public Administration in general, authorized recipients shall adhere to the highest levels of correctness and integrity, refraining from any form of pressure, whether explicit or veiled, aimed at obtaining any undue advantage for themselves or for Proramillenote SRL. In this regard, authorized recipients shall strictly observe the provisions of this Code, as well as, more generally, the directives issued by the management of Proramillenote SRL.
Relations with Political and Trade Union Organizations
Proramillenote SRL does not favor or discriminate against any political or trade union organization. The Company refrains from providing any undue contributions in any form to parties, unions, or other social formations, except for specific exemptions and always within the limits permitted by current regulations. Recipients are required to refrain from any direct, indirect, or implied pressure towards political figures or trade union representatives.
Relations with Customers and Suppliers
Recipients interact with third parties with courtesy, competence, and professionalism, believing that their conduct is crucial in protecting the image and reputation of the company and, consequently, achieving business objectives. In particular, recipients must refrain from any form of unfair or misleading behavior that could lead customers or suppliers to rely on unfounded facts or circumstances. Recipients are obligated to consistently strive to provide timely and high-quality services to customers, aiming to minimize any form of disruption or delay in order to maximize customer satisfaction. Relations with suppliers are based on loyalty, fairness, and transparency. Supplier selection is made based on objective criteria of cost-effectiveness, appropriateness, and efficiency. Choosing suppliers based purely on subjective and personal grounds, or due to conflicting interests with those of the company, is prohibited. Recipients must take all possible measures to ensure that suppliers and customers also adhere to the fundamental ethical principles outlined in this Code.
Internal Control System
The internal control system is aimed at adopting tools and methodologies designed to counteract potential business risks, in order to ensure compliance not only with the law but also with internal provisions and procedures. In fact, the violation of the principles set forth in the Code and the procedures indicated in the internal controls compromises the trust relationship between the Company and its directors, employees, consultants, various collaborators, customers, suppliers, and business and financial partners. Such violations will therefore be promptly and decisively pursued by Proramillenote SRL through the adoption of appropriate and proportionate disciplinary measures. The effects of violations of the Ethical Code and internal protocols must be taken into account by all those who, in any capacity, have relations with Proramillenote SRL.
Depending on the severity of the conduct exhibited by the person involved in one of the illicit activities outlined in the Code, Proramillenote SRL will promptly take the necessary measures, regardless of any possible criminal action by the judicial authority.
Notwithstanding the above, behaviors in violation of the Ethical Code constitute a serious breach for employees (workers, employees, executives, and managers) and are penalized with sanctions applied according to their severity, as provided for by the applicable national collective labor agreement (verbal warning, written warning, fine, suspension from work and pay, dismissal for just cause or justified reason).
In the event of pending criminal action or the execution of a personal liberty restriction measure taken against the employee, before adopting the disciplinary measure, the sanction of suspension from service and pay may be imposed, for a duration corresponding to the outcome of the criminal action or until the expiration of the personal liberty restriction measure.
The identification and application of sanctions will always take into account the general principles of proportionality and appropriateness concerning the violation in question.
In all of the aforementioned cases, Proramillenote SRL also reserves the right to take any actions deemed appropriate to seek compensation for damages suffered as a result of conduct in violation of the Ethical Code.
Guidelines for the Sanctioning System
Compliance with the provisions of this Code is entrusted to the prudent, reasonable, and careful supervision of each Recipient, within their respective roles and functions within the company.
All recipients are encouraged to report to their direct superiors any facts and circumstances that may conflict with the principles and provisions of this Code.
The management of Proramillenote SRL and the designated bodies take all necessary measures to put an end to any violations, being able to resort to any disciplinary measures in accordance with the law and the rights of workers, including trade union rights.
Via Monte Cervino, 70
20862 – Arcore
Monza e Brianza – Italy
CF – PIVA: 10323920966
Phone +39 039 616593
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